NC0075027_NOI_NOV2018PC0227_Response_20180809 (2)

Bradley FlyntBradley Flynt
Cainsway WWTP ORC
CC Ron Boone
Jenny Graznak
8467 Southard Rd.
Stokesdale, NC 27357
08/09/2018
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
450 West Hanes Mill Road
Winston-Salem, NC 27105
Dear Sherri V. Knight, P.E.:
This letter is in response to the Compliance Evaluation conducted by Ron Boone on June 5, 2018. He
found that the plant has gotten into poor and dilapidated condition due to corrosion which is an
ongoing problem with a lot of privately owned package plants. I have spoken to the Homeowner's
association President about this situation and he is willing to do whatever they can afford to start
getting the plant in better shape. I immediately provided a piece of schedule 80 PVC to replace the
leaking feed line to the aeration so corrosion will not be an issue with that line in the, future.
The missing bar screen is in the process of being evaluated for replacement. The original design is
too dangerous to be replaced like kind and we are in the talks with a contractor to build a stainless
steel bar screen in the influent splitter box or in the manhole that feeds the influent pump
station/EQ tank but is still easier to access than the EQ tank area.
The floating solids were due to the final clarifier sludge collector mechanism breaking down and
had just been repaired before the inspection so the old sludge that was trapped in the bottom of
the final was be introduced back into the plant for treatment and made the clarifier cloudy. I

.,
Sherri V. Knight, P.E.
08/09/2018
Page 2
started wasting thesesolids out and was able to clear the final up which couldn't be done before
the mechanism was fixed.
The composite sampler was reading 79.8 degrees Celsius on the LED display which is not correct. I
have installed a refrigerator thermometer to monitor temp and will see if display temp can be fixed.
Daryl Cain, Homeowner Association President, has been notified about the crushing of the declor
box will personally dig It up and fix himself within 30,days of this letter.
Sludge pumping records has been requested from the Homeowner's secretary and will be on site
soon and when I get them I will email a copy to Mr. Boone. If I can be of further assistance please
feel free to contact me at [phone]
Sincerely,
Bradley Flynt
Cainsway WWTP ORC
CC Ron Boone
Jenny Graznak

-
Water Resources
Environmental Quality
CERTIFIED MAIL 7015-0640.0005-8164.2357
RETURN RECEIPT REQUESTED
July 10, 2018
Cains Way Homeowners Association
Attn: Daryl Cain, Owner
2350 Huffine Mill Road
McLeansville, NC 27301
Subject; Compliance Evaluation Inspection & Notice of Violation
NOV Tracking #: NOV-2018-PC-0227 ,
Permittee: Cains Way Homeowners Association
Facility: Cains Way Mobile Home Park
NPDES Permit#: NCO075027
Forsyth County
Dear Mr. Alphin:
ROY COOPER
Governor
NUCHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Ron Boone, of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Resources (DWR or the
Division), conducted a compliance evaluation inspection (CEI) of the Cain's Way Mobile Home Park Wastewater
Treatment Plant (WWTP) on June 5, 2018. The assistance and cooperation of Mr. Bradley Flynt, Operator in
Responsible Charge (ORC), was greatly appreciated. An inspection checklist is attached for your records and
inspection findings are summarized below. . ,
I. Permit
The NPDES permit became effective April 1, 2017 and expires February 28, 2022. A copy of the permit was NOT
available on site during the inspection. Please ensure you provide one to Mr. Flynt to keep on site at all times.
II. Self -Monitoring Program
A review of the monthly discharge monitoring reports (DMR) for the period June 2013 through June 2018 showed that
the facility experienced 16 violations.during that time frame, all of which have already been addressed via separate
correspondence.
Flow Measurement
Flow is measured using an ISCO 4230 bubbler flow meter that was last calibrated November 215t, 2017. The meter
appeared to be functioning properly during the inspection according to Mr. Boone.
IV. Operations and Maintenance
Mr. Boone reports that the WWTP is in fair to poor condition. Many components throughout the treatment process are
severely corroded and/or dilapidated. In fact, the pipe that conveys wastewater into the flow splitter box from the influent
!/'Nothing Compares =�.
State of North Carolina I Environmental Quality
450 W. Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone: [phone] FAX: [phone]

E
pump station began leaking during the inspection due to severe corrosion. Cain's Way must consider doing some major
repair work to this facility. Once corrosion gains a foothold and goes unchecked, it can spread rather quickly and
eventually cause catastrophic failure. Plant condition is highly indicative of the amount of money and time invested into
the proper operation and maintenance of the facility over the years. If nothing is done to address the dilapidation of the
plant, we believe catastrophic failure is imminent, requiring significant investment from which to recover.
V. Facility Site Review
All components of this 0.04 million -gallon -per -day (MGD) facility appeared to be functional during the inspection, but
Mr. Boone did observe the following additional issues:
• The bar screen essentially came up missing at some time in the recent past. Mr. Flynt stated that it may have
fallen into the influent pump tank. The bar screen must be replaced as soon as possible. It is a permitted part
of the plant and allowing these solids to enter the rest of the plant can degrade the plaint's overall treatment
capacity.
• The dissolved oxygen (DO) level in the aeration basin was only 0.48 milligrams per liter (mg/1) during the
inspection. The desired range is 1.0 to 3.0 mg/1. It is questionable whether the plant can sufficiently treat the
waste load with this DO concentration. The planes aeration system may be insufficient. Please address this
issue in your written response to this letter.
• There were some floating solids in the clarifier, which were slowly making their way over the weir. This
apparently hasn't affected effluent quality but is indicative of older sludge in the clarifier. It may be prudent to
waste more sludge.
• The composite sampler's temperature reading was 79.8 degrees Celsius. Mr. Flynt stated that the reading is
inaccurate and that the temperature inside the sampler is, in fact, much lower and within proper range. He
indicated that the device that reads the temperature has failed. This must be repaired immediately so the
operator knows that samples are being stored at the proper temperature. It was noted in the 2016 inspection
report that the sampler's outer casing was cracked. Mr. Boone didn't notice if this is still the case, but it could
also be why the temperature is so high. Please indicate in your response letter whether a new sampler was
acquired to replace the one with a crack in it noted in the 2016 inspection, as well as what you intend to do to
repair it now.
• Composite samples are not flow proportional, as required by the permit, but WSRO granted Cain's Way
permission to use constant time/constant volume sampling by letter dated May 11, 2015. Please ensure Mr.
Flynt has a legible copy of this letter on site and available for inspection at all times.
• The dechlorination unit is being crushed by the soil it is buried in. The unit is still functional at this point but it
may at some point in the future become inoperable. You should consider reinstalling the unit properly, i.e. in
a container of some type, like a concrete vault, which provides protective structural support.
• As stated above, the severe corrosion throughout the plant is seriously concerning.
VI. Records/Reports
According to existing records, all required effluent monitoring has been performed in accordance with the parameters
and frequencies required by the NPDES permit. Chains of custody, operations and maintenance logs, operator's
visitation logs, etc., were all available for inspection.

Sludge records need to be improved. Not all sludge pumping records were available during the inspection. Please
VII. Effluent/Receivina Waters
Pin floc was flowing over the clarifier weir'troughs at the time of the inspection but none was seen in the effluent.
Effluent flow was clear and free of foam and solids during the inspection. Upstream and downstream sampling points
were visited and are clearly accessible. The plant discharges to Ader Creek, which is currently classified as Class C
waters and is located in the Roanoke river basin.
Please work with Mr. Flynt to correct the deficiencies noted above in paragraphs 1 and 4 through 7.Overall, the plant
must be better maintained and more should be invested in the plant's proper upkeep.
Please reply in writing to this letter within 30 business days of receiving it. You should also be able to provide the
requested sludge pumping/hauling records. Your written reply should address each of the noted deficiencies and
provide a corrective action plan along with an implementation/completion schedule to remediate them.
Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is
promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General Statute (NCGS)
143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your written reply within 30 business days
of your receipt of this notice, we may draft an enforcement case for the noted deficiencies/violations.
If you have any questions regarding the inspection or this report, please contact Ron Boone or me at [phone]
Sincerely,
4Sherri V. Knight, P.E.
/Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments:
BIMS Inspection Report
cc: Central Files
AW
NPDES Unit

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CERTIFIED MAILO REGEIF I
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■ Complete items 1, 2, and 3.
•. Print your name and address on the reverse
so that we can return the card to you.
■=Attach this card to the back of the mailpiece,
or on the front if space permits. _
Daryl Cain
Cains Way Homeowners Assn
2350 Huffine Mill Road
McLeansville, NC 27301
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United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20480
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-96
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmo/day Inspection Type Inspector Fac Type
1 IN I 2 15 I 3 I N00075027 I11 12 18,06/05 17
18 I C I 19 (!-I 20 LJ
21111111 11111111 1111111111111111111111111111
1�6
Inspection Work Days Facility Self -Monitoring Evaluation Rating 31 CA
Reserved
72 L.J
671 I 70ILJ 71LJ
73I74 75
80
Section B: FacilityData
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
11:24AM 18/06/05
17/04/01
Conaway Mobile Home Park
Exit TimelDate
Permit Expiration Date
Pinehall Rd
12:24PM 18/06/05
22/02/28
Walkertown NC 27051
Name(s) of Onsite Representative(s)frifles(s)/Phone and Fax Number(s)
Other Facility Data
///
Bradley Todd FtynUORC/336433-7262/
Name, Address of Responsible OfficiaVTitle/Phone and Fax Number
Contacted
Bradley Todd Ftynt,8467 Southerard Rd Stokesdale NC 27357//336433-7262/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit E Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program E Sludge Handling Disposal Facility Site Review EfguenUReceiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
Date
Ron Boone WSRO WO//336-776-9690/
J
Signature of Management O A Reviewer Agency/Office/Phone and Fax Numbers
// Dale
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

J
NPDES yr/molday Inspection Type
31 NCo075027 I11 12I 18/06/05 117 18 I C 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Please refer to the attached inspection summary letter.
Page#

Permit: NC0075D27
Inspection Date: 06/05/2018
Owner -Facility: Cainsway Mobile Home Park
Inspection Type: Compliance Evaluation
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
❑
0
❑
❑
Is all required information readily available, complete and current?
❑
E
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
E
❑
❑
Are analytical results consistent with data reported on DMRs?
E
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
0
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
0
❑
(If the facility is = or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
N
❑
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
E
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
E
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
Comment: Permit not on site Sludge removal records incomplete.
Permit
Yes
No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
E
❑
application?
Is the facility as described in the permit?
❑
0
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
-E
❑
❑
❑
Is the inspector granted access to all areas for inspection?
E
❑
❑
❑
Comment: Bar screen is no longer installed It is believed to have fallen into the influent
pump tank.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑
Are all other parameters(excluding field parameters) performed by a certified lab? ❑ ❑ ❑
Page# 3

Permit NCO075027
Inspection Date: 08/05/2018
Laboratory
Owner -Facility: Coinsway Mobile Home Park
Inspection Type: Compliance Evaluation
Yes No NA NE
# Is the facility using a contract lab?
E
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
E
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
❑
E
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
❑
i
Comment: The composite sampler must be fixed. Temperature indicator read 79.8 degrees Celsius
during the inspection. Mr. Flynt said that this isn't correct and the temperature
indicator/reader must be replaced. It must be replaced so we know that samples
are being
refrigerated to the proper temperature.
Effluent Sampling
Yes
No NA NE
Is composite sampling flow proportional?
❑
E
❑
❑
Is sample collected below all treatment units?
E
❑
❑
❑
Is proper volume collected? _
❑
❑
❑
Is the tubing clean?
N
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
0
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
E
❑
❑
❑
representative)?
Comment: The composite sampler must be fixed. Temperature indicator read 79.8 decrees Celsius
during the inspection. Mr. Flynt said that this isn't correct and the temperature
indicator/reader must be replaced. It must be replaced so we know that samples are being
refrigerated to the proper temperature.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and E ❑ ❑ ❑
sampling location)?
Comment: None
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Inaudible and visual alarm available and operational?
Yes No NA NE
■ ❑ ❑ ❑
❑ ❑ ❑ E
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ E ❑ ❑
■ ❑ ❑ ❑
Page# 4

t_
Permit: MCC075027
Inspection Date: 0810512018
Pump Station - Influent
Owner - Facility: Cainsway Mobile Home Park
Inspection Type: Compliance Evaluation
Comment: Cannot see into the tank to assess amount of grease.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Yes No NA NE
Yes No NA NE
Ext. Air
Diffused
❑
❑
❑
❑ .
❑
E
❑
❑
❑
❑
❑
❑
❑
■
❑
❑
❑
❑
■
❑
❑
❑
■
❑
❑
Comment: Mixed liquor was dark with very litte foa and dissolved oxygen was only 0.48 mg/I.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater? _
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑/
Is the site free of weir blockage?
E
❑
❑
❑
Is the site free of evidence of short-circuiting?
❑
❑
❑
Is scum removal adequate?
E
❑
❑
❑
Is the site free of excessive floating sludge?
E
❑
❑
❑
Is the drive unit operational?
S
❑
❑
❑
Isthe return rate acceptable (low turbulence)?
❑
0
❑
❑
Is the overflow clear of excessive solids/pin Floc?
❑
N
❑
❑
Is the sludge blanket level acceptable? (Approximately Y. of the sidewall depth)
❑
❑
❑
Comment: There are some floating solids More sludge may need to be returned or wasted
Pumps-RAS-WAS
Yes No NA NE
Are pumps in place?
E
❑ ❑
❑
Are pumps operational?
E
❑ ❑
❑
Are there adequate spare parts and supplies on site?
0
❑ ❑
❑
Comment: None
Page#
5

Permit: NG0075027 Owner -Facility:
Cainsway Mobile Home Park
Inspection Date: 06/05/2018 Inspection Type:
compliance Evaluation
-
Pumps-RAS-WAS
Yes No NA NE
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
E
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
N
❑
❑
❑ '
(If units are separated) Does the chart recorder match the flow meter?
E
❑
❑
❑
Comment: None
Disinfection -Tablet
Yes No NA NE
Are tablet chlorinators operational?
E
❑
❑
❑
Are the tablets the proper size and type?�
E
❑
❑
❑
Number of tubes in use?
4
Is the level of chlorine residual acceptable?
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
E
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
E
Comment: None
De -chlorination
Yes
No NA NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑
❑
❑
E
Is storage appropriate for cylinders?
0
❑
❑
❑
# Is de -chlorination substance stored away from chlorine containers?
0
❑
❑
❑
Are the tablets the proper size and type?
E
❑
❑
❑
Comment: None
Are tablet de -chlorinators operational? ❑ ❑ ❑
Number of tubes in use? 4
Comment: Dechlorinator is being crushed by soil it is buried in. It should be excavated and installed
Properly inside some sort of protective container such as a concrete vault.
Effluent Pipe
Yes
No NA NE
Is right of way to the outfall properly maintained?
E
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
E
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
S
❑
Page# 6

� z
4
Permit NCO075027
Inspection Date: 06/0512018
Effluent Pipe
Comment: None
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment: None
Owner -Facility: Cainsway Mobile Home Park
Inspection Type: Compliance Evaluation
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: None
Yes No NA NE
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
■
❑
❑
❑
❑
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Page# 7